December feels far away, but for GST annual returns, October is exactly when preparation should begin. GSTR-9 and GSTR-9C for FY 2025-26 (1 April 2025 to 31 March 2026) are due on 31 December 2026. This year’s return is more complex than usual because of the GST rate overhaul, known as GST 2.0, which took effect in the middle of the year. In this blog, we explain what has changed, who must file, and how to prepare without last-minute stress.
What Is GSTR-9?
GSTR-9 is the GST annual return. It pulls together everything you reported during the year in GSTR-1 and GSTR-3B, and it also reflects the input tax credit available from GSTR-2B. Think of it as a yearly summary that checks whether your monthly filings, taken together, tell a consistent story.
What Is GSTR-9C?
GSTR-9C is a reconciliation statement. It compares the figures in your GSTR-9 with your audited financial statements. Since FY 2020-21, it is self-certified by the taxpayer, not certified by an external auditor, though many businesses still take professional help to prepare it correctly.
Who Must File, and By When
- Turnover up to ₹2 crore: GSTR-9 is optional.
- Turnover above ₹2 crore: GSTR-9 is mandatory.
- Turnover above ₹5 crore: Both GSTR-9 and GSTR-9C are mandatory.
Both forms for FY 2025-26 are due on 31 December 2026. There is no separate due date for GSTR-9C; it is filed along with GSTR-9.
The Big Change This Year: GST 2.0 Rate Split
This is the part that makes FY 2025-26 different from every year before it.
The new GST rate structure, widely called GST 2.0, took effect on 22 September 2025. Before that date, most goods and services followed the familiar 5%, 12%, 18%, and 28% slabs. From 22 September 2025 onwards, the structure moved largely to 5%, 18%, and 40% for most items, with a few exceptions.
Because your financial year runs from 1 April 2025 to 31 March 2026, your GSTR-9 for this year contains two rate regimes in a single return. Supplies up to 21 September 2025 follow the old rates, and supplies from 22 September 2025 follow the new rates.
Here is the practical impact:
- Your outward supply figures in Table 4 need to be correctly split and reported for both periods.
- Your HSN-wise summary should reflect the correct rate for each period. Do not report the full year at one rate; that will not match your returns and can trigger a query.
- Credit notes or amendments relating to supplies from the earlier period but recorded after the rate change need special attention, since they may still refer to the old rate.
- If your pricing, invoicing, or billing software made errors during the transition period, GSTR-9 is where those errors become visible. It is better to find and fix them now, through your working papers, rather than at the department’s prompting.
Prepare a simple two-line reconciliation for every major product or service line: one line for 1 April to 21 September 2025, and one line for 22 September 2025 to 31 March 2026. This makes Table 4 and the HSN summary far easier to complete accurately.
A New Consequence for Missing the Deadline
In earlier years, missing the GSTR-9 deadline only meant a late fee. That is no longer the only consequence.
From FY 2025-26 onwards, if GSTR-9 is not filed by 31 December 2026, the portal is expected to block your GSTR-3B filing for January 2027 and every month after that, until the annual return is filed. In simple words, missing your annual return can stop your regular monthly compliance in its tracks. This makes 31 December 2026 a genuinely hard deadline this year, not just a target date.
Late Fee for GSTR-9
If you file late, the fee is ₹200 per day (₹100 under CGST and ₹100 under SGST), subject to a cap based on your turnover. The cap generally works out to 0.25% of your turnover in the relevant state or union territory. For a mid-sized business, this can add up quickly over even a few weeks of delay.
Documents and Data You Will Need
Start collecting these now so that nothing holds up the filing in December:
- GSTR-1 and GSTR-3B for every month of FY 2025-26 (April 2025 to March 2026), including amendments filed later
- GSTR-2B statements for the year, to check input tax credit claimed versus credit available
- Sales register and purchase register, ideally split at the 21/22 September rate-change date
- HSN-wise summary of outward supplies, prepared separately for the old and new rate periods
- Details of credit notes and debit notes issued during the year
- Reconciliation of e-way bills with invoices, where applicable
- For GSTR-9C: audited financial statements and a working reconciliation between book turnover and GST turnover
- Any notices, order copies, or demand details relevant to the year
A Second Deadline to Track: Last Date for ITC
Many businesses overlook that there is a separate deadline for claiming input tax credit relating to FY 2025-26 invoices. That deadline is 30 November 2026, or the date you file your GSTR-9 for the year, whichever is earlier. If you still have pending credit to claim for last year’s purchases, do not wait until December. You could lose the credit permanently.
Common Mistakes in GSTR-9 Filing
1. Mismatch between GSTR-1 and GSTR-3B. If your outward supply figures differ between these two returns, GSTR-9 forces you to explain the difference. Reconcile before you begin filing.
2. Claiming credit beyond the cut-off. Input tax credit missed before the 30 November cut-off, or before filing GSTR-9, generally cannot be claimed later.
3. Ignoring credit notes from the transition period. A credit note issued in October 2025 for a sale made in August 2025 needs careful rate treatment. Do not apply the new rate by default.
4. Treating GSTR-9C as a formality. Even though it is self-certified, the reconciliation must genuinely match your books. Errors here can attract scrutiny later.
5. Leaving it for late December. The GST portal gets slow and congested every year in the final week of December. File at least two to three weeks early if you can.
6. Forgetting pending GSTR-9 for earlier years. If you have any unfiled GSTR-9 for FY 2022-23 or later, this window is closing. Clear old pending returns alongside this year’s filing.
A Simple Filing Timeline for Your Business
To avoid the usual December rush, we suggest this timeline:
- October: Pull together GSTR-1, GSTR-3B, and GSTR-2B data for the full year. Split sales at the rate-change date.
- Early November: Reconcile GSTR-1 with GSTR-3B. Identify and claim any pending input tax credit before 30 November.
- Mid-November: Prepare the HSN-wise summary for both rate periods. Review credit notes and debit notes.
- Early December: Draft GSTR-9. For turnover above ₹5 crore, start GSTR-9C reconciliation with audited financials.
- Mid-December: Review the draft with your CA. Fix mismatches.
- Before 25 December: File both forms, well ahead of the portal rush and the hard deadline.
Frequently Asked Questions
Is GSTR-9 compulsory for my business?
Only if your turnover exceeds ₹2 crore for the year. Below that, it is optional.
Do I need GSTR-9C?
Only if your turnover exceeds ₹5 crore. It is self-certified, not certified by an external CA, though professional help is still valuable.
What if I miss the 31 December 2026 deadline?
You pay a late fee, and from this year, your GSTR-3B filing for later months can also get blocked until you file GSTR-9.
Can I still claim missed input tax credit for FY 2025-26?
Only until 30 November 2026, or until you file your GSTR-9, whichever is earlier.
Will the due date be extended?
The government has extended GSTR-9 deadlines in some past years, but there is no confirmed extension for FY 2025-26 as of now. Plan to file by 31 December 2026.
Final Words
This year’s GSTR-9 is not just a routine summary. The GST 2.0 rate change in the middle of the year means your books need an extra layer of care, and the new rule blocking future GSTR-3B filings raises the stakes for missing the date. The businesses that start reconciling now, rather than in late December, will avoid late fees, blocked filings, and rushed errors.
